Table of Contents

I CHARITABLE GIVING TODAY; 1. Size; 2. Scope; 3. Causes; II FUNDAMENTAL CONCEPTS RELATING TO CHARITABLE ORGANIZATIONS; 1. Private Inurement; 2. Public Benefit Versus Private Benefit; 3. Public Charities Versus Private Foundations; 4. Non profit Versus Tax-Exempt Versus Charitable; III U.S. LEGAL FRAMEWORK GOVERNING CHARITABLE ORGANIZATIONS; 1. Legal Structures; 2. US Taxation; IV US LEGAL CONSTRAINTS; 1. Private Foundation Rules; 2. Constraints on Cross-Border Giving; V WHY CREATE A FOREIGN CHARITY?; 1. The Bias in US Law Against Private Foundations; 2. Advantages of a Foreign Charitable Organization; VI PICKING A JURISDICTION; 1. Law; 2. Financial Services Infrastructure; 3. Professional Infrastructure; 4. Proximity / Access to the United States; 5. Reputation; 6. Language; 7. Costs; VII ESTABLISHING A FOREIGN CHARITABLE FOUNDATION; 1. US Tax Considerations; 2. Should the Foreign Entity Apply for Exempt Status in the United States?; 3. Governance Issues; VIII REPRESENTATIVE STRUCTURES; 1. Bermuda Charitable Trusts; 2. Barbados Charitable Trusts; 3. Bermuda Purpose Trusts; FURTHER RESOURCES; GLOSSARY OF TERMS; APPENDICES